Eqithra.com Privacy Policy

1. Data Controller

The controller of your personal data is:

• Company: Flamicroz OÜ
• Registry Code: 16478175
• VAT Number: EE102487327
• Legal Address: Annemäe tee 14, Rakvere linn, Lääne-Viru maakond, 44306, Estonia
• Phone: +372 5616 0996
• Email: info@eqithra.com

2. Purposes and Legal Bases for Data Collection

We collect and process personal data only for specific and lawful purposes. Below is a description of what data we process and for what purpose in different parts of our platform.

2.1. Platform Account Creation and Management

• Data processed: First and last name, email address, password (encrypted).
• Purpose: Creating a user account on the Platform, enabling login, and managing the account.
• Legal basis: Performance of a contract (acceptance of Terms of Use).

2.2. Data Processing in the Online Store (Seller: Flamicroz OÜ)

• Data processed: Customer name, contact details (phone, email), delivery address, purchase history, payment data.
• Purpose: Processing orders made from the Online Store, fulfilling the sales contract, delivering goods, issuing invoices, and customer communication regarding the order.
• Legal basis: Performance of a contract. For accounting-related data, also compliance with a legal obligation (Accounting Act).

2.3. Data Processing in the Marketplace and Horses Portal (Intermediary: Flamicroz OÜ)

In the Marketplace (including "Flea Market" and "Eqithra Horses"), our role is to provide an intermediary service or advertising environment that enables users to communicate and trade with each other.

Data processing for service provision:

• Data processed: Username, contact details, content of sales advertisements (including photos), transaction history, communication with other users via the platform's messaging system.
• Purpose: Ensuring the functioning of the service, including publishing advertisements, mediating transactions, and enabling user-to-user communication.
• Legal basis: Performance of a contract (acceptance of Terms of Use).

Processing data of Business Sellers (according to DSA):

• Data processed: Business seller's name, address, phone number, email address, commercial register code.
• Purpose: Ensuring transparency and reliability of transactions in accordance with Regulation (EU) 2022/2065 (Digital Services Act or DSA). Certain data is displayed to the buyer before the conclusion of the transaction.
• Legal basis: Compliance with a legal obligation.

Collection and transmission of tax information (according to DAC7):

• Data processed: Seller's name and address, personal or registry code, date of birth (for individuals), bank account number (IBAN), income earned quarterly, number of transactions.
• Purpose: As a platform operator, we are legally obliged to collect and transmit information to the Tax and Customs Board about sellers who earn income on our marketplace. We do not do this on our own initiative but fulfill a strict legal obligation arising from EU Directive 2021/514 (DAC7) and the Estonian Tax Information Exchange Act.
• Legal basis: Compliance with a legal obligation.
• Applicability: The reporting obligation extends to sellers who make 30 or more transactions per calendar year or whose total remuneration exceeds 2000 euros.

2.4. Customer Support and Marketing

• Data processed: Name, email address, content of communication.
• Purpose: Responding to your inquiries and questions. If you have given explicit consent, also sending newsletters and personalized offers.
• Legal basis: Our legitimate interest in providing high-quality customer service. For marketing, your consent, which you can withdraw at any time.

3. Transfer of Personal Data to Third Parties

We do not share your personal data with third parties unless necessary for the provision of the service or if we have a legal obligation to do so. Authorized processors of your data may include:

• Payment service providers: For secure processing of transactions.
• Transport companies: For delivering goods purchased from the Online Store.
• IT partners: Providers of maintenance and development services for our platform (e.g., server hosting, software development).
• Public sector authorities: As mentioned above, we transmit data to the Tax and Customs Board (DAC7) based on legal obligations or to other state authorities (e.g., police) upon justified request.

We have concluded agreements with all our partners ensuring that they process data securely and only according to our instructions.

4. Data Retention

We retain your personal data for as long as necessary to fulfill the purpose of data collection or until the expiration of legal requirements.

• Accounting-related data is retained for 7 years in accordance with the Accounting Act.
• Data related to contractual relationships is retained until the end of the limitation period for civil claims (generally 3 years).
• User account and related data are retained as long as the account is active. Upon deletion of the account, we delete data for which we have no other legal basis for retention.

5. Your Rights Regarding Personal Data

You have the following rights regarding your personal data:

• Right of access: You have the right to receive information about whether and what data we process about you and to receive a copy of it.
• Right to rectification: You have the right to request the correction of inaccurate or incomplete data.
• Right to erasure ("right to be forgotten"): You have the right to request the deletion of your data if we no longer have a legal basis for processing it.
• Right to restriction of processing: Under certain conditions, you have the right to request the temporary suspension of processing your data.
• Right to object: You have the right to object to the processing of your data based on our legitimate interest.
• Right to data portability: You have the right to receive data you have submitted to us in a machine-readable format, processed automatically based on a contract or consent.
• Right to withdraw consent: If data processing is based on your consent (e.g., newsletters), you have the right to withdraw it at any time.

To exercise your rights, please contact us using the contact details provided in Section 1.

6. Cookies

Our platform uses cookies to ensure service functionality, improve user experience, and analyze web traffic. For more detailed information on cookies and their management, please see our Cookie Policy.

7. Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. We use secure connections (SSL) and restrict access to data only to those employees and partners who need it to perform their duties.

8. Dispute Resolution and Supervisory Authority

If you have any questions or concerns regarding the processing of your personal data, please contact us directly. We will do our best to resolve all issues.

You also always have the right to file a complaint with the Data Protection Inspectorate:

• Address: Tatari 39, Tallinn 10134, Estonia
• Email: info@aki.ee
• Website: www.aki.ee

9. Changes to Privacy Policy

We reserve the right to update this Privacy Policy from time to time. We will notify you of significant changes via the platform or email. The valid version is always published on our website.